SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
AE segmental benchmarking under TNMM requires consideration of segmental results included in the transfer-pricing study and certified information furnished before completion of the transfer-pricing assessment. Neither the Act nor the Rules requires audited segmental accounts; where the AE-segment margin falls within the arm's-length range of selected comparables, rejection on conjectural grounds is unwarranted and the related adjustment is deleted. Ind AS presentation of part of compulsorily convertible debentures as equity does not change their underlying debt character before actual conversion or redemption. Interest remains deductible in principle, subject to verification that no conversion or redemption occurred during the relevant year.
AE segmental benchmarking under TNMM requires consideration of segmental results included in the transfer-pricing study and certified information furnished before completion of the transfer-pricing assessment. Neither the Act nor the Rules requires audited segmental accounts; where the AE-segment margin falls within the arm's-length range of selected comparables, rejection on conjectural grounds is unwarranted and the related adjustment is deleted. Ind AS presentation of part of compulsorily convertible debentures as equity does not change their underlying debt character before actual conversion or redemption. Interest remains deductible in principle, subject to verification that no conversion or redemption occurred during the relevant year.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
